How To Initiate a Mercury Clean Out in Your School

Getting Started

Develop a team

This may include the science coordinator, science teachers, health & safety officers, school nurse, building & grounds personnel and school administrators.

Develop a plan

Decide how many and what type of schools will be participating? (i.e. secondary, middle, or elementary school, or all of them) Who will be in charge of compiling the mercury inventory? Will you use a hazardous waste recycler or can you use a local household hazardous waste collection event? Will there be a mercury collection pickup at each participating school, or will there be a centralized collection pick up stop? Who will collect and pack up the mercury-containing items? How will you get the appropriate packing containers? Where will the collected mercury-containing items and containers be stored? These are the kind of questions that your team will probably want to explore and develop into a plan of action.

Obtain approval from the administration

Direction and assistance from the "top" can motivate team members.

Training

Be sure that members of the team have training on proper handling of hazardous wastes and training on how to use a mercury spill clean up kit. You should have a mercury spill kit available before initiating your mercury clean out.

The Hazardous Waste Recycler

Schools often will hire a hazardous waste recycler to dispose/recycle their mercury. Shop around and see who can offer you the most competitive bid. Look out for hidden costs!! Are there extra costs for containers to pack the mercury into, or are they included in their cost quote? Are there different costs for different types of mercury - elemental mercury versus mercury compounds? The related web link in the right column entitled "Fluorescent and HID Lamp Recyclers" is for recyclers of fluorescent lamps (all fluorescent lamps do contain mercury). Most of the recyclers listed may also manage your other mercury wastes (elemental mercury¹, mercury compounds and mercury-containing equipment).

Recycling Containers

A photo of two five-gallon plastic lidded buckets

Five-gallon plastic buckets

Fiber-drum container for recycling mercury

a fiber drum container

Typically, the hazardous waste recycler will send five-gallon plastic, lidded buckets (15 inches high) to pack the mercury wastes into. For larger mercury-containing equipment, such as a barometer, you can arrange with the hazardous waste recycler for a fiber drum container.

New York State Requirements

Before commencing with your mercury clean out, schools should familiarize themselves with New York State Regulations.

Elemental mercury is no longer allowed to be purchased or used in schools, as of September 4, 2004, according to the Environmental Conservation Law, Article 27, Title 21.

The Universal Waste Rule was created to reduce the amount of hazardous waste entering the solid waste stream, to encourage recycling and proper disposal, and to ease the regulatory burden on generators. There are many advantages for using the Universal Waste Rule:

Less paperwork (manifest and annual reports are not required)
Universal wastes are not counted toward your generator status
You may self transport or use a common carrier
You can consolidate universal wastes for shipment at one location from satellite locations.

The Universal Waste Rule manages common hazardous waste such as batteries, certain pesticides, fluorescent lamps (whole lamps only) and mercury-containing equipment (MCE). Examples of MCE are thermometers, barometers, manometers, flow meters, mercury switches, mercury regulators, water treatment gauges, gas safety relays, sphygmomanometers (blood pressure cuffs) and thermostats. Equipment or other wastes contaminated with mercury are NOT regulated as universal waste and must be managed accordingly.

A Universal Waste Handler is anyone who generates, manages, receives, accumulates, or sends universal wastes to another universal waste handler or to a destination facility. A Small Quantity Handler (SQH) is a handler who accumulates less than 5,000 kilograms (11,000 pounds) of total universal waste onsite at anytime. A Large Quantity Handler (LQH) is a handler who accumulates 5,000 kilograms (11,000 pounds) or more of total universal waste onsite at any time.

Small Quantity Handler:
You must manage your universal waste in a way that prevents releases to the environment as follows:

Contain any universal waste in containers or packages that are structurally sound, adequate to prevent leaks, spills or damage, and compatible with contents.
Contain all releases of universal waste and other residues and determine whether any material resulting from the release is hazardous. If the materials is hazardous, it must be managed accordingly.
Inform employees who handle or manage the waste of the proper handling and emergency procedures.
May accumulate universal wastes for up to one year from when it became a waste. Label each waste or container as "Universal Waste Batteries/Lamps/MCE, etc." and the date it became waste.
You are prohibited from sending universal wastes or taking it to a place other than another Universal Waste Handler or destination facility.
May self transport universal wastes without a Part 364 hazardous waste transporters permit if less than 500 pounds of universal waste is on the same vehicle.
Recordkeeping is not required, but is strongly recommended.

Large Quantity Handler:
Must meet all the requirements for SQH's and:

Notify EPA in writing and receive an EPA identification number.
Keep a record of all universal waste shipments received or sent off-site. You must retain those records for at least three years from the date of receipt or shipment.

Any one who transports universal wastes offsite are Universal Waste Transporters!

In New York State, if you are transporting more than 500 pounds of universal waste in a vehicle, you must have a Part 364 transporter's permit, and all shipments must be in compliance with the New York State's Department of Transportation.

Mercury to be Managed as Hazardous Waste

The following must be managed and disposed of by standard hazardous waste regulations:

Elemental mercury¹ not contained in equipment (see footnote)
Mercury compounds
Mercury spill clean up materials
Broken or crushed fluorescent lamps (not already stored in UW containers)
Items contaminated by elemental mercury (i.e. clothing, shoes, jewelry, backpacks, carpeting)

There are three kinds of hazardous waste generator categories:

Conditionally Exempt Small Quantity Generators (CESQG) - generates no more than 100 kilograms of hazardous waste in a month and less than 1 kilogram of acute hazardous waste (and stores no more than 1,000 kilograms)

Small Quantity Generators (SQG) - generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste in a month and less than 1 kilogram of acute hazardous waste (and stores less than 6,000 kilograms)

Large Quantity Generators (LQG) - generates at least 1,000 kilograms of hazardous wastes in a month, and less than or at least 1 kilogram of acute hazardous waste

Most schools will probably fall into the CESQG category. If you are a CESQG you have to follow these guidelines:

Consolidation points can receive hazardous waste from offsite, without permit, if wastes are only from CESQG's.
CESQG's can self-transport up to 100 kilograms of their own hazardous wastes in one calendar month (otherwise, they must use a permitted transporter).
There are no manifests, no EPA ID#, no required paperwork, although recordkeeping is strongly recommended.
Hazardous wastes must be counted toward generator status.
When transporting hazardous waste, you must also conform to United States Department of Transportation (USDOT) requirements for packaging, placarding and any other requirement for hazardous material.

For information on SQG and LQG guidelines, or for more in-depth information on New York State's Hazardous Waste Regulations, check out the DEC website by clicking the link in the right column entitled "Information on NYS Hazardous Waste Regulations. For USDOT information, call their Hotline at 1-800-467-4922 and ask for help with hazardous materials shipping requirements.

To determine your hazardous waste generator designation, you add up all the hazardous waste generated at your school from all sources, not just from mercury sources! (i.e. hazardous wastes from art rooms, labs, maintenance shops, bus garages, etc.)

The Mercury Clean out Process:

Use a mercury inventory form

Mercury can be found in some, not so obvious, equipment like:
thermostats, switches, boilers, fluorescent lamps and fire alarm pull stations.

A mercury inventory form can help jog teachers' memories and helps keep track of the amount of mercury to be collected.

You can use the form developed by the DEC, in partnership with the New York State Department of Health. That web link is:
www.nyhealth.gov/nysdoh/environ/hsees/hsees.htm (Go there by clicking on the link under Offsite Links in the right column).

Tip: Make sure that you include the size, as well as the number of the mercury-containing items collected on your mercury inventory form. This information will be vital when you get to the collection part of your mercury clean out. Make sure that you have the right size and number of containers on hand before you get to the collection.

The Mercury Collection

Get in the Door!!
If you are not part of building's and grounds staff, than you will want to coordinate ahead of time with the school
custodians, the "keepers of the keys."
Coordinate with the Teachers.
Have them clearly mark locations for the mercury pick-up. Avoid the time-consuming frustration of having a "treasure hunt" for mercury items in science labs and classroom storage areas.
Confirm mercury items being collected with the items listed on the mercury inventory.
It is not uncommon to find an inventory mismatch.
Separate mercury compounds from containers of elemental mercury and mercury-containing items.
Mercury compounds need to be packed in a container separate from the elemental mercury and mercury-containing equipment (check with your recycler for details.)
Double bag, wherever possible.

Place the mercury-containing item either in two plastic bags, one inside the other, or in a plastic jar placed inside a plastic bag. Zip lock bags work well. Seal the jar, and/or bags with masking or duct tape).
Get prior notification about any broken mercury-containing equipment.
Broken items should be properly contained by double-bagging or by putting broken mercury-containing equipment into a plastic jar with the lid taped shut. We recommend that you have a mercury spill cleanup kit on hand, just in case.

Packing the Containers

Sometimes a school will contract with a recycler to pack up the containers, as well as dispose/recycle the mercury waste.

However, if your school decides to pack the containers, here are some tips:

Usually, the hazardous waste recycler does not provide the packing material. You can use packing "peanuts," vermiculite, even plastic bags or newspaper. The idea is to pack the mercury-containing items so as not to have breakage in the containers.
Don't over pack the container! However, you don't want to under pack the container, either. A hazardous waste recycler usually charges per bucket. Keep an "eye on costs" and maximize the use of each container.
Label each container "Contains Elemental Mercury and Mercury-Containing Items" or "Contains Mercury Compounds," as appropriate.

Storage

There usually is a time-lag from the time of the mercury collection to the time when the hazardous waste recycler comes to pick up the containers.

Store the marked containers in a locked cabinet or storage room until they are transported off-site to avoid unauthorized removal or handling of containers, especially by students.

Mercury Spill Guidance:

If you have a minor mercury spill, under two tablespoons, here are some steps that you should follow:

Evaluate the room immediately
Contain the spill. Tape works well.
Open exterior windows; shut down interior ventilation; lower room temperature
Keep potentially contaminated individuals in a separate area until they can clean up and change clothes. Treat contaminated items as hazardous waste.
Put all mercury and contaminated materials into double containment and label it for proper disposal. It must be disposed of as a hazardous waste.

NEVER throw mercury down the drain.
DO NOT use a broom, mop or vacuum cleaner to clean up a mercury spill.

Heat from a vacuum cleaner will accelerate the vaporization of mercury and contaminate the vacuum cleaner, which must then be disposed of as hazardous waste. Using a mop or broom will only spread the mercury around the floor, contaminating the mop and broom, which must then be disposed of as hazardous waste.

Broken Fluorescent Lamp Clean Up:

Wear gloves
DO NOT vacuum or sweep up broken items
Use a damp cloth to collect shards of glass and phosphor powder
Place all spill clean up materials in a puncture-resistant, sealed plastic container or bag
Do not place broken lamps and clean-up materials in trash. Broken fluorescent lamps should be disposed of as hazardous waste; they cannot be disposed of as universal waste.

If a fluorescent lamp breaks on a carpet, the contaminated section of the carpet must be cut out and disposed of appropriately as hazardous waste, or a professional mercury spill clean-up contractor may be called. They may have other safe, alternative methods to clean the carpet.

You are required to report a mercury spill of one pound (two tablespoons) or more to the New York State DEC Spill Hotline: 1-800-457-7362.

You hope it doesn't get to this point, when you have to call in the professionals to clean up a significant mercury spill!

It's costly both in time and in money!!

When can a mercury spill lead to health problems??

Even a fever thermometer break, which contains one gram of mercury, can lead to symptoms if it is not cleaned up properly. Some people are more sensitive to mercury's toxic effects, and children, in particular, are more vulnerable to mercury's toxicity.

Mercury spills, which contain 100-200 grams or more of mercury, obviously have more potential to cause harm.

Most severe cases of mercury poisoning result from extended exposure.

A person repeatedly playing with elemental mercury
Elemental mercury spill not properly cleaned up, continuously "off-gassing" toxic mercury vapors.

Mercury spills involving heat can result in greater exposures, as mercury can readily vaporize at higher temperatures. Mercury vapor is particularly toxic to humans. 80 percent of mercury vapors inhaled goes directly to the brain and nervous system.

Mercury-Free Equipment:

Almost all mercury-containing equipment found in schools can be replaced by non-mercury substitutes of equal functionality!

The second component of our pilot project allowed for the purchase of mercury-free equipment to replace mercury-containing items that were disposed of by the participating schools in Rochester City and Albany County school districts.

Some typical examples of mercury-free equipment are as follows:

Enviro-Safe Thermometers - feature biodegradable non-toxic (green-colored) fluid, certified calibration, white background. Ranges are -20 to +110 degrees C, -10 to +260C degrees C, and -20 to +150 degrees C.

Alcohol Thermometers - Methyl alcohol thermometers (red fluid). Drawback is that they are less accurate than the Enviro-Safe thermometers.

Digital Thermometers - are required for higher temperatures. Ranges are -58 to 1999 degrees F, and -50 to 1200 degrees C for the higher cost thermometer. Drawback with using digital is that it probably uses a button cell battery that contains mercury.

Eco-Celli Liquid Silicon Gas Barometers - uses a red, non-toxic silicon fluid and gas, an contains a methyl-alcohol thermometer. A sliding scale between two tubes compensates for thermal expansion of the silicon fluid due to changes in room temperature and allows for accurate measurement of air pressure.

Aneroid Sphygmomanometer - features Velcro cuffs, chrome air valves, and latex inflation systems. They include zippered vinyl pouches.

Out of the $50,000 grant, $39,767.66 was spent for 2,385 mercury-free pieces of equipment for the 48 schools that participated from the City of Rochester and Albany County school districts. Because the costs for the mercury clean out was so inexpensive, the bulk of the grant monies could be used for purchasing mercury-free equipment replacements.

Replacement costs will be much more expensive than the actual mercury clean out costs, but taken in balance with the costs for a mercury spill clean up, it still makes good "cents"!!

For more information on Reducing Mercury in Schools, please contact:

Deborah Knight, Environmental Program Specialist
(518) 402-9485 or E-mail: depprmt@gw.dec.state.ny.us

Please drop Ms. Knight an email to let us know about your mercury clean out at your school. We are particularly interested in knowing how much mercury was disposed of and what types of mercury were cleaned out.

Other Links of Interest (see Offsite Links in the right column):
EPA's mercury website: www.epa.gov/mercury
DOH mercury spill brochure: www.nyhealth.gov/nysdoh/environ/hsees/mercury_brochures

Don't wait until there is a mercury spill incident at your school to spur a mercury clean out! Close the book on "Mean, Mad, Mercury"!

¹Elemental mercury that has not been used (such as surplus mercury removed from a laboratory's chemical supply inventory) is excluded from being a hazardous waste, as a commercial chemical product, destined for reclamation, pursuant to 6NYCRR371.1(c)(4)(iii)

More about How To Initiate a Mercury Clean Out in Your School:

Reducing Mercury in Schools - A Pilot Project - Reducing Mercury in Schools-A Pilot Project